2023 (2) TMI 1161

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....e Nos.ITBA/APL/S/250/2021-22/1036818962(1) and ITBA/APL/S/250/2021-22/1039080137(1), in proceedings u/s 154 and 143(3) r.w.s. 153A of the Income Tax Act, 1961, in short "the Act". Latter assessment year 2018-19 involves assessee's and Revenue's cross appeals ITA Nos.47 and 59/PUN/2021 directed against the very CIT(A)'s DIN & order No. ITBA/APL/S/250/2020-21/1029367933(1), dated 30.12.2020 in proceedings u/s 143(3) of the Act. Heard both the parties. Case files perused. 2. It transpires during the course of hearing that the assessee's twin appeals IT(SS)A Nos. 12/PUN/2021 and 11/PUN/2022 for former assessment year 2017-18 hardly requires us to delve deeper in the relevant factual matrix. This is for the precise reason that neither the Asse....

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.... 3. This leaves us with the latter assessment year 2018-19 wherein both the assessee as well as the Revenue have filed their respective appeals ITA Nos.47 & 59/PUN/2021; respectively. The sole issue that arises for our apt adjudication in both these appeals is that of "telescoping" of section 69A unexplained money addition of Rs.1,66,40,000/- made by the Assessing Officer which has been partly allowed to be set off in CIT(A)'s order to the extent of Rs.1,18,22,400/- vide following detailed discussion: This leaves both the parties aggrieved to the extent indicated in their respective pleadings. The assessee's case before us not only seeks to delete the impugned section 69A addition of Rs.1,66,40,000/- in entirety but also learned counsel ....